COMMUNITY 

POLICING HIRING 

GRANTS

Grant Application and 

Monitoring Processes 

Could Be Improved to 

Further Ensure 

Grantees Advance 

Community Policing

Report to Congressional Requesters

September 2013

GAO-13-521

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-521, a report to 

congressional requesters 

September 2013

COMMUNITY POLICING HIRING GRANTS 

Grant Application and Monitoring Processes Could Be 

Improved to Further Ensure Grantees Advance 

Community Policing

Why GAO Did This Study

Since its 1994 inception, the U.S.

Department of Justice’s (DOJ) COPS 

Office has awarded roughly $14 billion 

in grants to support the advancement 

of community policing, which is a 

policing approach that proactively 

addresses the conditions that give rise 

to public safety issues, such as crime 

and social disorder. GAO was asked to 

review key grant management 

practices within the COPS Office. This 

report focuses on the largest of its 

programs—CHP, which awards grants

to law enforcement agencies to hire 

law enforcement officers, rehire 

officers who have been laid off, or 

prevent scheduled officer layoffs. This 

report addresses: (1) From fiscal years 

2008 through 2012, in what areas of 

the country was CHP funding 

disbursed and to what extent did award 

amounts vary during this period? (2) 

To what extent does the COPS Office’s 

grant application collect information 

about how applicants plan to use CHPfunded officers to advance community 

policing? (3) To what extent does the 

COPS Office’s monitoring process 

assess whether grantees are using 

funds to advance community policing?

GAO examined budget data and 

monitoring reports for 55 grantees, 

interviewed agency officials, and 

evaluated CHP applications from a 

systematic random sample of 103 CHP 

grants awarded from fiscal years 2010 

through 2012. 

What GAO Recommends

GAO recommends that the COPS 

Office revise and clarify the CHP 

application and enhance guidance to 

require monitors to document their 

analysis results of non-supplanting in 

monitoring reports. The COPS Office 

generally concurred with the 

recommendations and described 

actions to address them.

What GAO Found

Nearly half of the Office of Community Oriented Policing Services (COPS) Hiring 

Program (CHP) funding from fiscal years 2008 through 2012 was awarded to 

grantees in six states, and award amounts varied considerably in certain years. 

During this period, state, county, and city law enforcement agencies nationwide 

received CHP grant awards to hire or rehire officers to advance community policing, 

with 48 percent of the funds awarded to grantees in California, Florida, Michigan, 

New Jersey, Ohio, and Texas. For grantees awarded the same number of officers, 

differences were driven mainly by variation across grantees’ respective entry-level 

officer salaries and benefits. Variation in grantee award amounts were more 

prominent during 2009, 2010, and 2011, when salary and benefit levels were not 

statutorily capped, and grantees with higher officer salary and benefit levels generally 

received more CHP funding relative to other CHP grantees for the same number of 

officers. 

The COPS Office’s CHP application collects information required by statute from 

grant applicants, but could be further enhanced by revising the application to clarify 

for applicants that CHP-funded officers are required to be the personnel specifically 

engaged in the community policing activities described on the application. The 

application asks applicants to provide information on how they plan to implement 

community policing agency-wide, but does not specifically ask applicants to explain 

how CHP-funded officers will be deployed in community policing—the primary 

statutory purpose of the CHP program. According to GAO analysis of a systematic 

random sample of 103 CHP-funded applications, GAO estimated that less than 20 

percent of the applications funded in 2010, 2011, and 2012 contained evidence 

showing how additional officers would be deployed in community policing. The 

Domestic Working Group’s guide for grant accountability recommends that agencies 

require applicants to include information describing, among other things, their 

approach for using the funds and the specific activities that are crucial to the success 

of the program. Revising the application to clarify for applicants that CHP-funded 

officers are required to be the personnel specifically engaged in the community 

policing activities described on the application, consistent with best practices, would 

better position the COPS office to ascertain from applicants how these particular 

officers’ activities would advance community policing.

The COPS Office’s risk-based approach to monitoring assesses how grantees are 

using funds to advance community policing, but could be improved through additional 

monitoring guidance. The authorizing statute for the COPS grant programs contains a 

prohibition against supplanting— using federal funds to replace state or local funds. 

The COPS Office developed standards and an operations manual for monitors to use 

in assessing the potential for supplanting. For 5 of the 21 grantees at risk for 

supplanting, GAO found that the monitors did not document their analyses of 

supplanting and it was not clear how they reached conclusions regarding supplanting.

The manual requires monitors to document their supplanting analysis in instances in 

which supplanting is identified, but does not have this requirement for nonsupplanting. According to internal control standards, the documentation of agency 

activities is a key element of accountability for decisions. By enhancing the COPS 

Office’s monitoring guidance to require monitors to document their results where the 

determination is made that supplanting has not occurred, the COPS Office may be 

better positioned to ensure that monitors are consistently assessing supplanting and 

that CHP funding is supplementing and not replacing state and local funding.

View GAO-13-521. For more information, 

contact David C. Maurer at (202) 512-9627 

or maurerd@gao.gov. 
Page i GAO-13-521 Community Policing Hiring Grants

Letter 1 

Background 6

Nearly Half of CHP Funding In the Past 5 Years Was Awarded to 

Grantees in Six States, and Award Amounts Varied Considerably 

in Certain Years 13

The COPS Office’s CHP Application Collects Information Required 

by Statute, but Could Be Further Enhanced by Clarifying that 

CHP-Funded Officers Are Required to Be Engaged in 

Community Policing Activities 19

The COPS Office’s Monitoring Process Assesses How Grantees Are 

Using CHP Funds to Advance Community Policing, but Could Be 

Improved through Additional Monitoring Guidance 22

Conclusions 28

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 29

Appendix I Objectives, Scope, and Methodology 33

Appendix II How Proactive and Reactive Policing Differ 38

Appendix III Comments from the Department of Justice 40

Appendix IV GAO Contact and Staff Acknowledgments 44

Tables

Table 1: Grant Programs Managed by the COPS Office from Fiscal 

Years 2008 through 2012 9

Table 2: Annual Changes in Specific COPS Hiring Program (CHP) 

Award Provisions from Fiscal Years 2008 through 2012 11

Table 3: Community Oriented Policing (COPS) Office Grant Risk 

Assessment Tool Criteria Examples 23

Table 4: Community Oriented Policing (COPS) Office Supplanting 

Identification Guidance for Monitors 26

Table 5: How Proactive and Reactive Policing Differ 38

Contents 
Page ii GAO-13-521 Community Policing Hiring Grants

Figures

Figure 1: How Proactive and Reactive Policing Differ. 8

Figure 2: Geographic Dispersion of COPS Hiring Program (CHP) 

Grant Awards, Number of Officers Funded, and CHP 

Compensation, Fiscal Years 2008 through 2012 

(Interactive Graphic) 14

Figure 3: Total COPS Hiring Program Funding by State from Fiscal 

Years 2008 through 2012 15

Figure 4: Average Annual COPS Hiring Program (CHP)-Funded 

Officer Salary and Benefits among CHP Grantees, by State 

and Territory, from Fiscal Years 2009 through 2011 17

Abbreviations

CHP COPS Hiring Program

CHRP COPS Hiring Recovery Program

COPS Office of Community Oriented Policing Services

CPD Community Policing Development

CSPP Child Sexual Predator Program

DOJ Department of Justice

GAT Grant Assessment Tool

ICAC Internet Crimes Against Children

IG Inspector General

OAAM Office of Audit, Assessment, and Management

OJP Office of Justice Programs

SOS Secure Our Schools

TRGP Tribal Resources Grant Program

UHP Universal Hiring Program

VCCLEA Violent Crime Control and Law Enforcement Act of 1994

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-13-521 Community Policing Hiring Grants

441 G St. N.W.

Washington, DC 20548

September 25, 2013

The Honorable F. James Sensenbrenner, Jr.

Chairman

Subcommittee on Crime, Terrorism,

 Homeland Security, and Investigations

Committee on the Judiciary

House of Representatives

The Honorable Lamar Smith

House of Representatives

Since its 1994 inception, the U.S. Department of Justice’s (DOJ) Office of 

Community Oriented Policing Services (COPS)—known as the COPS 

Office—has awarded roughly $14 billion in grants to law enforcement 

agencies to support the advancement of community policing, which is a 

policing approach that proactively addresses, through law-enforcementcommunity engagement, the conditions that give rise to public safety 

issues, such as crime, social disorder, and fear of crime.1 Though the 

focus of grant funding over time has varied, COPS Office funding has 

supported, among other things, police officer hiring, drug education 

programs, and law enforcement technologies to advance community 

policing. From 1995 through 2002, the average annual COPS 

appropriation was more than $1 billion.2 Beginning in fiscal year 2003, 

annual appropriations for the program, in general, started to decrease. 

The average annual appropriation for the COPS program from 2003-2012 

(excluding the $1 billion in funding COPS received under the American 

 

1

Prior to the 1994 establishment of the COPS Office, in December 1993, DOJ’s Bureau of 

Justice Assistance awarded community policing grants to hire officers under the Police 

Hiring Supplement Program, which was established by the Supplemental Appropriations 

Act of 1993, Pub. L. No.103-50, 107 Stat. 241, 246 (1993). In this report, when we refer to 

COPS Office funding dating back to 1993, we are including this program. 

2

The year 1995 was the first in which the COPS Office administered funds appropriated 

for community policing. 

 
 

Page 2 GAO-13-521 Community Policing Hiring Grants

Recovery and Reinvestment Act of 20093) was approximately $596 

million.4

In recent years, Members of Congress expressed interest in improving 

oversight and accountability of federal grant programs; for example, the 

House Committee on the Judiciary held a hearing on oversight of the 

COPS Office in 2012.5 During the 2012 hearing, a Member of Congress 

noted concerns about the extent to which COPS grants had been used 

for purposes consistent with program goals and whether or not 

supplanting—using federal funds to replace state or local funds—had 

occurred. Our prior work on DOJ grants has identified opportunities to 

improve DOJ grants administration. Specifically, in our prior review of 

overlap among DOJ grant programs, we recommended that the Attorney 

General, among other things, assess DOJ grant programs, including the 

COPS grant program, for potential overlap and harmonize departmental 

business processes for grants management.6 Our past work on grants 

management across the federal government has found that opportunities 

exist to improve the design and implementation of federal grants: in 

particular, data collection and validation.7 Additionally, for the past 10 

years, the DOJ Office of Inspector General (IG) has identified grant 

 

3

Pub. L. No. 111-5, 123 Stat. 115, 130. 

4 For fiscal year 2013, the appropriation for the COPS Program is $209.7 million, after 

taking into account the reduction to all nonexempt appropriations accounts based on the 

March 1, 2013, sequestration.

5 Hearing on the U.S. Department of Justice Community Oriented Policing Services 

Office” February 29, 2012 (Serial No. 112-97). 

6

GAO, Justice Grant Programs: DOJ Should Do More to Reduce the Risk of Unnecessary 

Duplication and Enhance Program Assessment, GAO-12-517 (Washington, D.C: July 12, 

2012). We made eight recommendations to ensure that DOJ can identify overlapping 

grant programs to either consolidate or coordinate similar programs, mitigate the risk of 

unnecessary grant award duplication in its programs, and enhance DOJ’s ability to gauge 

grant program effectiveness. DOJ has taken steps to partially address these 

recommendations, although they still remain open. 

7

GAO, Grants Performance: Justice and FEMA Collect Performance Data for Selected 

Grants, but Action Needed to Validate FEMA Performance Data, GAO-13-552

(Washington, D.C.: June 24, 2013); Grants to State and Local Governments: An Overview 

of Federal Funding Levels and Selected Challenges, GAO-12-1016 (Washington, D.C.: 

Sept. 25, 2012), and Grants Management: Enhancing Performance Accountability 

Provisions Could Lead to Better Results, GAO-06-1046 (Washington, D.C.: Sept. 29, 

2006). 
 

Page 3 GAO-13-521 Community Policing Hiring Grants

management among its list of top management challenges.8 The level of 

federal spending on grant programs combined with the federal 

government’s continued long-term fiscal challenges and constrained 

budget underscores the importance of ensuring that agencies employ 

sound grants management practices.

You requested that we review the COPS Office funding trends and the 

office’s overall grant management and oversight practices of its 

community policing grants. The COPS Hiring Program (CHP) and its 

predecessors, the Universal Hiring Program (UHP) and the COPS Hiring 

Recovery Program (CHRP)—in this report referred to collectively as 

CHP—account for 68 percent of the funds that the COPS Office has 

awarded through its various grant programs from fiscal years 2008 

through 2012.9 This report focuses on the CHP program, and answers the 

following questions: (1) From fiscal years 2008 through 2012, in what 

areas of the country was CHP funding disbursed and to what extent did 

award amounts vary during this period? (2) To what extent does the 

COPS Office’s grant application collect information about how applicants 

plan to use CHP-funded officers to advance community policing? (3) To 

what extent does the COPS Office’s monitoring process assess whether 

grantees are using funds to advance community policing?

To address the first question, we reviewed the history of the COPS 

Office’s programs and related award data from the most recent 5 fiscal 

years—2008 through 2012—and confirmed that CHP received the largest 

share of funds as compared with other programs administered by the 

COPS Office during this period. We also analyzed COPS Office 

documentation, such as the Grant Owner’s Manuals and COPS Office 

website materials, to learn about each program’s origin and emphasis. To 

determine which areas of the United States have received CHP funding, 

we analyzed the allocation of CHP grant awards—and the numbers of 

 

8

Additionally, the DOJ OIG issued a report in 2009 on the COPS Office which identified 

six steps intended to improve the office’s awarding and monitoring of grants. DOJ Office of 

the Inspector General, Improving the Office of Community Oriented Policing Services’ 

Grant Awarding, Monitoring, and Program Evaluation Processes, (Washington D.C.: June, 

2009). 

9

UHP grants were awarded in 2008, and COPS Hiring Recovery Program grants were 

awarded in 2009; both grant programs, like CHP, sought to advance community policing 

by supporting the hiring or rehiring of officers or helping grantees to avoid scheduled 

officer layoffs. 
 

Page 4 GAO-13-521 Community Policing Hiring Grants

officers funded—by state and mapped the CHP grant award data. 

Additionally, we analyzed CHP award lists for fiscal years 2008 through 

2012 to determine the average CHP entry-level officer salary and benefits 

by state and territory, and assessed them for variation.10 To ensure the 

reliability of data used in our review, we interviewed COPS Office officials 

about the integrity of the data they provided to us and reviewed system 

tests that the COPS Office conducts periodically to ensure data reliability. 

We determined that the data were sufficiently reliable for the purposes of 

our report. We also interviewed COPS Office officials to determine what 

factors could account for variations in grant award amounts and to learn 

about other administrative aspects of the program.

To address the second question, we examined the CHP authorizing 

statute, the CHP application, and the COPS Office’s criteria for selecting 

awardees. We compared the CHP application with the CHP authorizing 

statute and best practices for grants management, including practices for 

designing applications, identified by the Domestic Working Group.11

Additionally, we selected a systematic random sample of 103 CHP 

applications, out of 841, that the COPS Office funded from the 3 most 

recent fiscal years—2010 through 2012—and reviewed them for their 

level of detail in describing applicants’ planned use of funds.12 The results 

of this review are generalizable to all 841 funded applications.13 Further, 

 

10In our review of grant award lists from fiscal years 2008 through 2012, we reviewed the 

years 2009 through 2011 together as one group, because during this period awards were 

not subject to statutory salary and benefit caps; thus the COPS Office awarded each 

grantee the full amount it cost the grantee to pay the salaries and benefits of each funded 

officer. We reviewed 2008 and 2012 individually because in both fiscal years 2008 and 

2012, salary caps were in place, as we discuss later in the report. 

11Domestic Working Group, Grant Accountability Project, Guide to Opportunities for 

Improving Grant Accountability (Washington, D.C.: October 2005). The Domestic Working 

Group first convened in 2005 to provide a forum for audit organizations to identify ways to 

improve grant accountability. It is composed of federal government inspectors general and 

other state and local audit organizations, and is chaired by the Comptroller General of the 

United States.

12A systematic random sample is a method of sample selection in which the population is 

listed in some order, in this instance dollar amount of grant awarded, and every kth 

element is selected randomly for the sample. We selected 2010 through 2012 because 

they reflected the most recent active CHP awards, each of which remains open for a 3-

year grant term.

13With the finite population correction factor, the precision for estimates drawn from this 

sample is no greater than plus or minus 9 percentage points at the 95 percent level of 

confidence.
 

Page 5 GAO-13-521 Community Policing Hiring Grants

we conducted interviews with a nonprobability sample of 20 CHP 

grantees in five metropolitan areas to understand how they were using 

their awards at the local level. We selected these grantees based on the 

amount of the CHP award each grantee received, geographical variation, 

and the population size served by the grantee. The results of these 

interviews were not generalizable, but provided illustrative examples of 

the activities in which grantees engaged with their CHP funds. Finally, we 

interviewed COPS Office officials who oversee the application process to 

gather further information on the design of the application, including how 

the applications were scored.

To address the third question, we obtained and examined the monitoring 

reports for 55 grantees awarded CHP grants from the 3 most recent fiscal 

years: 2010 through 2012.14 The COPS Office produces these reports 

following the on-site monitoring visits it conducts with grantees to assess 

their progress and identify compliance issues, such as supplanting, for 

CHP grants. We then compared these monitoring reports with COPS 

Office guidance, such as its grant-monitoring standards, as well as with 

Standards for Internal Control in the Federal Government and best 

practices for grant program management from the Domestic Working 

Group, to evaluate the extent to which the monitors assessed whether 

grantees had used grant funds to supplant local funds.15 Additionally, we 

discussed the COPS Office’s grant-monitoring practices with officials from 

DOJ’s Office of Audit, Assessment, and Management (OAAM) to discuss 

 

14As with the grant applications we selected for review, we selected these 3 years 

because they reflected the most recent active CHP awards, each of which remains open 

for a 3-year grant term. These 55 grantees were all of the grantees from this period for 

which the COPS Office had completed CHP grant-monitoring reports at the time we began 

our audit. As discussed later in the report, these grantees are selected using risk-based 

monitoring criteria.

15GAO, Standards for Internal Control in the Federal Government, GAO/AIMD 00-21.3.1

(Washington, D.C.: November 1999); COPS Office, Grant Monitoring Standards and 

Guidelines for Hiring and Redeployment (Washington D.C.: Sept. 16, 2004) and Grant 

Monitoring Division Monitoring Operations Manual: Administrative and Compliance

(Washington D.C.: May 4, 2010); Domestic Working Group, Grant Accountability Project, 

Guide to Opportunities for Improving Grant Accountability (Washington, D.C.: October 

2005).
 

Page 6 GAO-13-521 Community Policing Hiring Grants

its role in oversight of monitoring activities at the COPS Office.16 We also 

interviewed COPS Office officials who oversee the monitoring process 

about their monitoring practices, and the extent to which on-site reviews 

enable them to identify and document instances of potential supplanting. 

Finally, we obtained the perspective of the COPS Office on the 

performance of its grant monitors in assessing and documenting 

instances of potential supplanting identified during our review of 

monitoring reports. Appendix I contains further information on our scope 

and methodology.

We conducted this performance audit from August 2012 to September 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The Public Safety Partnership and Community Policing Act of 1994, as 

amended, authorizes grants to states, units of local government, Indian 

tribal governments, other public and private entities, and multijurisdictional or regional consortia for a variety of community policingrelated purposes.17 Among other things, this includes the hiring and 

rehiring of law enforcement officers for deployment in community policing 

and developing and implementing innovative programs to permit 

members of the community to assist law enforcement agencies in the 

prevention of crime in the community. The act also requires that grantees 

not supplant state and local funding, but rather use the federal funds for 

 

16OAAM works to improve and enhance programmatic oversight for the Office of Justice 

Programs (OJP), as well as the COPS Office and the Office on Violence Against Women. 

OAAM has four main responsibilities: (1) ensure financial grant compliance and auditing of 

OJP’s internal controls to prevent waste, fraud, and abuse; (2) conduct program 

assessments of OJP and COPS Office grant programs; (3) oversee monitoring activities; 

and (4) serve as a central source for grant management policy.

17Enacted as Title I of the Violent Crime Control and Law Enforcement Act of 1994, Pub. 

L. No. 103-322, 108 Stat. 1796 (codified as amended at 42 U.S.C. §§ 3796dd – dd-8). 

Background 

Community Policing
 

Page 7 GAO-13-521 Community Policing Hiring Grants

activities beyond what would have been available without a grant.18 To 

administer the grant funds authorized by the act, the Attorney General 

created the COPS Office in October 1994. Since 1994, the COPS Office 

has awarded roughly $14 billion to advance community policing through 

its various grant programs.

The COPS Office defines community policing in its CHP applications and 

Grant Owner’s Manual, issued annually, as “a philosophy that promotes 

organizational strategies, which support the systematic use of 

partnerships and problem-solving techniques, to proactively address the 

immediate conditions that give rise to public safety issues, such as crime, 

social disorder, and fear of crime.”

19 The CHP grant applications describe 

some of these terms:

• community partnerships: collaborative partnerships between the 

law enforcement agency and the individuals and organizations they 

serve to both develop solutions to problems and increase trust in 

police;

• organizational transformation: the alignment of organizational 

management, structure, personnel and information systems to support 

community partnerships and proactive problem-solving efforts; and

• problem solving: the process of engaging in the proactive and 

systematic examination of identified problems to develop effective 

responses that are rigorously evaluated.

A characteristic of community policing is its emphasis on proactive 

policing—an approach to preventing crime—which is contrasted with 

traditional, reactive policing—an approach that responds to crime—both 

of which the interactive figure 1 illustrates.

 

1842 U.S.C. § 3796dd-3. For the purpose of COPS Office grants, supplanting means using 

COPS Office grant funds to replace state or local funding—or, in the case of Indian tribal 

governments, funding supplied by the Bureau of Indian Affairs—that otherwise would have 

been spent on the specific law enforcement purpose of the COPS Office grant award.

19Developed by the COPS Office to ensure that all CHP grantees clearly understand and 

meet the requirements of the grant, the CHP Grant Owner’s Manual assists agencies with 

the administrative and financial matters associated with the CHP grant. 
Page 8 GAO-13-521 Community Policing Hiring Grants

Source: GAO.

Proactive policing

Reactive policing

911

Crime problem 

identification 

Intelligence gathering Crime analysis Intervention

Reactive policing responds to crime after it has occurred.

Proactive policing attempts to prevent crime from occurring. 

Resolution

$

$

Police response Intervention

Interactive graphic Figure 1: How Proactive and Reactive Policing Differ

Move the mouse over the icons to view more information. This additional information is also reproduced in appendix II for readers of printed copies.
 

Page 9 GAO-13-521 Community Policing Hiring Grants

From fiscal years 2008 through 2012, the COPS Office managed 10 

programs designed to advance community policing. As table 1 illustrates, 

these 10 programs provided funding to target crime issues, such as 

school violence, as well as to hire officers or develop crime-fighting 

technology, among other things.

Table 1: Grant Programs Managed by the COPS Office from Fiscal Years 2008 through 2012

Program Description and fiscal years grants were awarded Amount funded

Percentage of 

total funds

COPS Hiring Program (CHP), 

COPS Hiring Recovery 

Program (CHRP), and COPS 

Universal Hiring Program 

(UHP)

Available to law enforcement agencies to hire law enforcement 

officers, re-hire law enforcement officers who have been laid 

off, or prevent scheduled law enforcement officer layoffs in 

order to advance community policing. The funded law 

enforcement officers must be engaged in community policing, 

or an equal number of the grantee’s veteran law enforcement 

officers must be redeployed to community policing. Awarded in 

fiscal years 2008-2012.a $1,681,555,221 68

Technology programs Available to non-federal law enforcement agencies to develop 

technologies to advance community policing and help fight 

crime. Awarded in fiscal years 2008-2010. $533,638,587 21

Tribal Resources Grant 

Program 

Available to support implementation or enhancement of 

community policing efforts by tribal law enforcement agencies 

to implement or enhance community policing efforts. Designed 

to increase collaboration between law enforcement agencies 

and members of the community by providing a variety of 

funding options including officer background investigations, 

basic and specialized law enforcement training, uniforms, 

standard issue equipment, department-wide technology, and 

police vehicles. Awarded in fiscal years 2008-2012. $133,809,157 5 

Secure Our Schools Available to non-federal law enforcement agencies and schools 

to work collaboratively to purchase crime prevention equipment 

and to provide safety training to staff and students to improve 

security and prevent violence at schools and on school 

grounds. Awarded in fiscal years 2008-2011. $59,493,666 2 

Child Sexual Predator 

Program 

Available to nonfederal law enforcement agencies that district 

U.S. Attorney’s Offices or the U.S. Marshals Service nominated 

to establish or enhance strategies to locate, arrest, and 

prosecute child sexual predators and exploiters through support 

for such efforts as Internet Crimes Against Children (ICAC) task 

forces, as well as enforce state sex offender registration laws. 

ICAC is a network of 61 task forces composed of federal, state, 

local, and tribal law enforcement and prosecutorial agencies 

that engage in investigations, forensic examinations, and 

prosecutions of Internet crimes against children. Awarded in 

fiscal years 2008-2011. $40,885,133 2 
 

Page 10 GAO-13-521 Community Policing Hiring Grants

Program Description and fiscal years grants were awarded Amount funded

Percentage of 

total funds

Community Policing 

Development 

Available to public governmental agencies, profit and non-profit 

institutions, universities, community groups, and faith-based 

organizations to advance the practice of community policing 

through training and technical assistance, the development of 

innovative community policing strategies, applied research, 

guidebooks, and best practices. Awarded in fiscal years 2008-

2012. $27,508,645 1 

Tribal Methamphetamine 

Enforcement Program

Available to tribal law enforcement agencies to support their 

participation in the development of comprehensive strategies to 

combat methamphetamine production, use, and trafficking in 

tribal communities. Awarded in fiscal years 2010-2011. $7,720,838 Less than 1

Safe Schools Initiative Available to state and local agencies to assist in delinquency 

prevention, community planning and development, school 

safety resources, and technology development. Awarded in 

fiscal years 2008- 2010. $9,487,963 Less than 1

Total $2,494,099,210 Less than 100b

Source: GAO analysis of COPS Office documents and award information.

a These grants were awarded under the UHP program in fiscal year 2008; the CHRP program in fiscal 

year 2009; and the CHP program in fiscal years 2010, 2011, and 2012.

b Percentages do not sum to 100 because of rounding.

As table 1 indicates, CHP accounted for 68 percent of the funds awarded 

through the COPS Office’s various grant programs. The program provides 

these funds over a 3-year term, on a reimbursable basis, meaning that 

the COPS Office approves grants for a specified number of officer hires 

or rehires—in cases where officers have previously been laid off—but 

provides the funding to the law enforcement agencies once these officers 

are onboard. Grantees must use the funds to hire or rehire additional 

officers for deployment in community policing or can redeploy a 

commensurate number of experienced locally funded officers to 

community policing after the entry-level officers are hired with CHP funds. 

By law, each year CHP funding must be split in such a way that the total 

grant funding awarded to each eligible state—meaning the sum of the 

grants awarded to applicants in that state—equals at least one-half of 1 

percent of the total CHP funding appropriated by Congress for that year.20

At the same time, the law requires that CHP funding be evenly split 

between entities serving jurisdictions with populations exceeding 150,000 

people and those serving jurisdictions with populations of 150,000 or 

 

2042 U.S.C. §3796dd(f). 

COPS Hiring Program
 

Page 11 GAO-13-521 Community Policing Hiring Grants

fewer.21 Specific award provisions, such as salary and benefit caps per 

officer funded; grantee fund-matching requirements; and other nuances, 

including a recent emphasis on the hiring of veterans, have varied each 

year since the CHP’s first authorization, in 1994. For example, in 2008 

and 2012, pursuant to the statutory requirements for the grant program, 

grantees were required to match the CHP award with at least 25 percent 

of local nonfederal funds and salary caps of $75,000 and $125,000, 

respectively, applied. However, under the American Recovery and 

Reinvestment Act (Recovery Act) these requirements did not apply in 

2009, 2010, and 2011.22 Table 2 highlights changes in the CHP during 

the past 5 fiscal years that affected the amount of funding available to 

applicants as well as which applicants received funding.

Table 2: Annual Changes in Specific COPS Hiring Program (CHP) Award Provisions from Fiscal Years 2008 through 2012

Year

Statutory salary and benefits cap (per officer, 

spread over the 3-year grant period) Other provisions

2008 Up to 75 percent of the approved entry-level salary 

and benefits (and thus a 25 percent local share) and 

a maximum federal share of $75,000 per officer 

position over 3 years. 

Emphasized violent crime task force participation.

2009 Officer salary and benefits were not capped; no local 

share was required.

None. 

2010 Officer salary and benefits were not capped; no local 

share was required.

Required that the number of officers an applicant requested could not 

exceed 5 percent of the law enforcement agency’s sworn force for a 

maximum of 50 officers. For agencies with a sworn force of fewer 

than 20 officers, awards were limited to 1 officer. CHP grantees were 

selected from the pool of 2009 COPS Hiring Recovery Program 

(CHRP) applications submitted in the prior year that were not funded, 

or received partial funding of their capped request.

2011 Officer salary and benefits were not capped; no local 

share was required.

Required that the number of officers requested could not exceed 5 

percent of agency’s sworn force for a maximum of 25 officers. For 

agencies with a sworn force of less than 20 officers, awards were 

limited to 1 officer.

 

2142 U.S.C. §§ 3793(a)(11)(B), 3796dd(h). In addition, an appropriate amount of available 

funds is to be made available for grants to Indian tribal governments or tribal law 

enforcement agencies.

22Two of the primary purposes of the Recovery Act were to “preserve and create jobs and 

promote economic recovery” and “stabilize State and local government budgets, in order 

to minimize and avoid reductions in essential services and counterproductive State and 

local tax increases.” Pub. L. No. 111-5, § 3, 123 Stat. 115, 115-16.
 

Page 12 GAO-13-521 Community Policing Hiring Grants

Year

Statutory salary and benefits cap (per officer, 

spread over the 3-year grant period) Other provisions

2012 Up to 75 percent of the approved entry-level salary 

and benefits (and thus a 25 percent local share) and 

a maximum federal share of $125,000 per officer 

position over 3 years.

Emphasized hiring veterans. Agencies whose requests were fully 

funded in fiscal year 2011, or that received 25 officer positions, were 

not eligible to apply. CHP grantees were selected from the pool of 

2011 applications submitted in the prior year that were not funded, or 

received partial funding of their capped request.

Source: GAO analysis of COPS Office documents and COPS authorizing statute and appropriations.

To select grantees for CHP, the COPS Office requires applicants to 

respond electronically to closed-end questions and provide a narrative 

description of the crime problems they are facing, among other things, in 

their grant applications. For example, one of the close-ended questions 

asks applicants to add a check mark if their agencies’ strategic plans 

include specific goals or objectives relating to community partnerships or 

problem solving. Another close-ended question provides response 

categories for applicants to select the ways in which their agencies share 

information with community members. According to COPS Office officials, 

in consultation with the Associate Attorney General and the Deputy 

Attorney General, they establish weights for (1) community policing 

questions, (2) questions pertaining to the applicants’ fiscal health, and (3) 

reported crime levels. They then score the applications and award funds 

to those applicants with the highest scores. For example, in fiscal years 

2009 and 2010, fiscal health accounted for 50 percent, crime rates 

accounted for 35 percent, and community policing activities accounted for 

15 percent of the total score.23

To monitor grantee performance, the COPS Office requires, as a term 

and condition of its grants, that grantees participate in grant-monitoring 

and -auditing activities, which can include programmatic and financial 

reviews of their funded activities. Accordingly, COPS Office officials 

stated that all grantees are required to submit quarterly progress reports 

that provide financial and programmatic information, such as their 

progress in implementing the community policing plan they described in 

their grant applications for utilizing CHP funds to advance community 

policing. According to the COPS Office, the goal of its monitoring is to 

assess grantees’ stewardship of federal funding, performance, innovation, 

and community policing best practices resulting from COPS Office 

 

23In fiscal year 2011, fiscal health accounted for 20 percent, crime rates accounted for 30 

percent, and community policing activities accounted for 50 percent of the total score. The 

COPS scoring process varies from year to year.
 

Page 13 GAO-13-521 Community Policing Hiring Grants

funding. In addition, according to the COPS Office, because of the 

number of COPS Office grantees, the COPS Office selects a limited 

number of grants to monitor based upon a grantee’s level of risk.24 In 

addition to the size of the grant award, such risk factors include, but are 

not limited to, whether or not the grantee

• has prior federal grant experience,

• has submitted late reports of its progress or failed to submit progress 

reports entirely, and

• has requested grant extensions.

As the interactive map in figure 2 illustrates, CHP grant awards were 

distributed throughout the United States from fiscal years 2008 through 

2012.

 

24From 2010 through 2012, the COPS Office awarded 841 CHP grants, of which 55 were 

selected for on-site monitoring.

Nearly Half of CHP 

Funding In the Past 5 

Years Was Awarded to 

Grantees in Six 

States, and Award 

Amounts Varied 

Considerably in 

Certain Years
 

Page 14 GAO-13-521 Community Policing Hiring Grants

The interactive map can be accessed here:

http://www.gao.gov/products/GAO-13-521

Figure 2: Geographic Dispersion of COPS Hiring Program (CHP) Grant Awards, 

Number of Officers Funded, and CHP Compensation, Fiscal Years 2008 through 

2012 (Interactive Graphic)

As figure 3 illustrates, 48 percent of the funding was awarded to grantees 

in six states—California, Florida, Michigan, New Jersey, Ohio, and Texas. 

Across all the states, grantees in California received the highest level of 

total CHP funding from 2008 through 2012. Specifically, total CHP awards 

in California equaled approximately $360 million, or more than 20 percent 

of the total CHP funding awarded.
 

Page 15 GAO-13-521 Community Policing Hiring Grants

Figure 3: Total COPS Hiring Program Funding by State from Fiscal Years 2008 through 2012

Note: Territories displayed include: Guam (GM), the Northern Mariana Islands (MP), Puerto Rico 

(PR), and the U.S. Virgin Islands (VI).

Officials from the COPS Office cited several factors that influenced the 

allocation of grant funds across the states and territories. In particular, 

officials pointed to the population-based statutory provision described 

previously, which requires the COPS Office to allocate 50 percent of 

available grant funding to jurisdictions with populations exceeding 

150,000 and 50 percent to jurisdictions with a population of 150,000 or 

fewer. Officials noted that some states—for example, California—have 

more cities with populations exceeding 150,000 compared with other 

states. This enables a smaller number of states to compete for half of the 

total grant funding, while a greater number of states without cities of this 

size compete for the remaining half of the total. Further, these large cities 

tend to receive larger awards because they deploy comparatively more 

officers than smaller cities. Apart from a separate statutory provision, also 

described previously, which requires that each state receive at least onehalf of 1 percent of the total CHP funding appropriated by Congress each 

year, COPS Office officials emphasized that a grantee’s particular 

location is not prioritized over the application categories of community 

policing, crime data, and fiscal health. Regarding fiscal health, officials 

noted that certain states have been disproportionately affected by fiscal 
 

Page 16 GAO-13-521 Community Policing Hiring Grants

distress, a factor that is directly reflected in the fiscal health component of 

the CHP application. Finally, the number of law enforcement agencies—

and thus potential applicants—varies across states, which contributes 

additional variation in how funding is ultimately distributed.

For grantees awarded the same number of officers, differences were 

driven mainly by variation across grantees’ respective entry-level officer 

salaries and benefits—the only costs CHP allows. However, this variation 

was more prominent during years when salary and benefit levels were not 

statutorily capped: 2009 through 2011.25 Thus, during the period 2009 

through 2011, grantees with higher officer salary and benefit levels

generally received more CHP funding relative to other CHP grantees to 

hire, rehire, or prevent layoffs for the same number of officers. For 

example, in fiscal year 2011, a grantee in California received a CHP 

award equivalent to its entry-level officer salary and benefits level of 

$150,753 per officer. In the same fiscal year, a grantee in Connecticut 

received a CHP award—also based on its entry-level officer salary and 

benefits—of $64,459 per officer per year. As a result of these local 

variations in per officer cost, this particular Connecticut grantee received 

and used 57 percent less federal funding to support each officer it hired or 

rehired compared with its California counterpart in this example. 

According to COPS Office officials, geographical differences in the cost of 

living could partly contribute to wage differences. Additionally, the 

availability of state and local budgetary resources to support law 

enforcement salaries and benefits may have affected wages. Further, 

COPS Office officials stated that other factors unique to certain areas of 

the country could account for the wage disparity that drives CHP costs. 

For example, some agencies may participate in more expensive state 

retirement systems or may not be able to set wages that align with market 

conditions because of union labor contract obligations. Figure 4 displays 

the average annual CHP-funded officer salary and benefit levels, by state 

and territory, for awards made from fiscal year 2009 through 2011—the 

years in which CHP grants awards were not capped.

 

25Pursuant to statutory authorization for CHP, awards are generally capped at $75,000; in 

2008, this cap applied. In 2009, the Recovery Act eliminated the cap for fiscal years 2009 

and 2010. This also applied to 2011 funds, because DOJ was operating under a 

continuing resolution, which provides budget authority for federal agencies to continue to 

fund their operations at a level consistent with previous year funding in the absence of 

annual appropriations. In 2012, appropriations language established a $125,000 cap. 
 

Page 17 GAO-13-521 Community Policing Hiring Grants

Figure 4: Average Annual COPS Hiring Program (CHP)-Funded Officer Salary and Benefits among CHP Grantees, by State 

and Territory, from Fiscal Years 2009 through 2011

Note: Territories displayed include Guam (GM), the Northern Mariana Islands (MP), Puerto Rico (PR), 

and the U.S. Virgin Islands (VI).

In contrast, statutory salary and benefit caps were in place for fiscal years 

2008 and 2012; thus during these years, each grantee was limited to 

receiving the same per officer maximum, irrespective of local differences 

in salary and benefit levels. Any officer-related expenses over and above 

the cap were the independent funding responsibility of the grantee and 

were not covered by CHP funding. As a result, less variation in award 

amounts occurred in fiscal years 2008 and 2012—when there was a 

cap—as compared with fiscal years 2009, 2010, and 2011—when there 

was no cap. According to DOJ officials, some additional variation in 

average award amounts occurred in 2012 as a result of the COPS Office 

exercising statutory authority allowing the COPS Office Director to waive 

the $125,000 salary and benefit cap, as well as the matching requirement 
 

Page 18 GAO-13-521 Community Policing Hiring Grants

when awarding grants.26 In 2012, the COPS Office granted 41 local 

match-and-cap waivers out of the 248 applicants that had requested 

them.27

Our analysis shows that interest in CHP funding remains high with the 

$125,000 per officer cap. From fiscal years 2008 through 2012, the COPS 

Office received more requests for CHP funding in grant applications than 

it could accommodate. The cap for fiscal year 2013 is $125,000, and in 

the President’s budget request for fiscal year 2014, the cap remains at 

$125,000.

 

2642 U.S.C. §§ 3796dd(g), 3796dd-3(c); Consolidated and Further Continuing 

Appropriations Act, Pub. L. No. 112-55, div. B, 125 Stat. 618-19. The COPS Office 

Director may waive the requirement of both the officer funding cap for the hiring program 

and the minimum 25 percent local matching requirement for grantees. According to COPS 

Office officials, the COPS Office Director grants waivers for applicants that show the 

highest demonstrated need for financial assistance based upon the scored financial health 

section of the CHP grant application. 

27CHP grantees in California received a majority of the waivers of the $125,000 salary and 

benefit award caps for fiscal year 2012. 
 

Page 19 GAO-13-521 Community Policing Hiring Grants

The CHP application solicits information from applicants in accordance 

with statute, but the COPS office may realize benefits by revising the 

application to clarify for applicants that CHP-funded officers are required 

to be the personnel specifically engaged in the community policing 

activities described on the application.28 The statute authorizing COPS 

Office grant programs requires applications, including the CHP 

application, to gather information from applicants related to several items, 

including, but not limited to the applicant’s 

• explanation of how the grant will be used to reorient its mission toward 

community policing or enhance its involvement in or commitment to 

community policing,

• specific public safety needs,

• inability to address the needs without federal assistance,

• plans for obtaining support at the conclusion of federal funding, and

• detailed implementation plan and long-term strategy that reflects 

consultation with community groups and appropriate private and 

public agencies.29

The statute does not further specify the content of these items, 

particularly the content of the detailed implementation plan and long-term 

strategy. However, the 2012 CHP application requires applicants to 

provide related information, such as how applicants plan to reorient their 

mission toward or enhance their involvement in or commitment to 

community policing. Specifically, COPS Office officials reported that the 

Law Enforcement & Community Policing Strategy section of the 

application is intended to obtain information from applicants to address 

the requirements of a detailed implementation plan and long-term 

strategy. For instance, this section requires applicants to include 

information on the crime problem that will be addressed with grant funds, 

information sources that will be used to improve the understanding of the 

problem and determine whether the response was effective, and the 

partnerships the agency will form.

 

28Since grantees can, after hiring entry-level officers with CHP funds, redeploy a 

commensurate number of experienced locally funded officers to community policing to 

satisfy the requirements of the grant, we are also referring to the activities of experienced 

locally funded officers deployed in support of community policing when we discuss the 

activities of CHP-funded officers. 

2942 U.S.C. § 3796dd-1. 

The COPS Office’s 

CHP Application 

Collects Information 

Required by Statute, 

but Could Be Further 

Enhanced by 

Clarifying that CHPFunded Officers Are 

Required to Be 

Engaged in 

Community Policing 

Activities
 

Page 20 GAO-13-521 Community Policing Hiring Grants

The application further requires applicants to indicate the community 

policing activities their entire agency was currently engaged in as well as 

those activities their organization intended to enhance or initiate with CHP 

funds. The fiscal year 2012 application notes that the COPS Office 

recognizes that CHP-funded officers will engage in a variety of community 

policing activities and strategies, including participating in some or all 

aspects of the applicant’s implementation plan. However, the application 

does not specifically ask applicants to explain how CHP-funded officers 

will be deployed in community policing—the primary purpose of the CHP 

program as expressed by the statute.30 For instance, the application does 

not ask applicants to provide information on what community policing 

activities, such as attending community meetings, CHP-funded officers 

will be undertaking.

The Domestic Working Group’s guide for improving grant accountability 

provides best practices for designing grant applications, including specific 

elements that are recommended to be addressed in grant applications.31

The Domestic Working Group, composed of federal government 

inspectors general and chaired by the Comptroller General of the United 

States, created the guide to share useful and innovative grant 

management approaches with government executives at the federal, 

state, and local levels.32 Specifically, the Domestic Working Group’s guide 

recommends that agencies require applicants to

• submit a detailed narrative as evidence of proper work planning to 

obtain and evaluate information from applicants when making award 

decisions, and

• include information to link grant activities with results, which is often 

referred to as logic modeling. As part of the logic model approach, 

applicants should, among other efforts, identify the need for funding, 

their approach to using the funds, specific activities that are crucial to 

the success of the program, and desired objectives and benefits 

 

3042 U.S.C. § 3796dd(b)(1)–(2).

31Domestic Working Group, Grant Accountability Project, Guide to Opportunities for 

Improving Grant Accountability (Washington, D.C.: October 2005).

32Although the Domestic Working Group Guide provides numerous recommendations for 

overall grant management, we focused our review on those criteria most pertinent to the 

design of grant applications. 
 

Page 21 GAO-13-521 Community Policing Hiring Grants

anticipated—and then logically connect these efforts to a plan for 

measuring results.

We found through our analysis of a systematic random sample of 103 

CHP-funded applications for fiscal years 2010, 2011, and 2012 that the 

application could be enhanced by applying these best practices to clarify 

for applicants that CHP-funded officers are required to be the personnel 

specifically engaged in the community policing activities described on the 

application. According to our analysis of the application sample, we 

estimate that less than 20 percent of the applications funded in these 

years contained evidence showing how additional officers would be 

deployed in support of community policing. 33

Several of the questions in the 2010, 2011, and 2012 applications ask for 

information on the agency-wide actions grantees plan to undertake to 

facilitate community policing. COPS Office officials reported that 

individual CHP-funded officers are expected to implement the items 

indicated in the implementation plan. These actions could include 

implementing recruitment and hiring practices that reflect an orientation 

toward problem solving and community engagement, enhancing 

information technology systems, and implementing organizational 

performance measurement systems that include community policing 

metrics. COPS Office officials agreed that the application could be clearer 

by stating the requirement that CHP-funded officers should be the ones

who are specifically engaged in CHP-funded activities.

Revising the application to clarify for applicants that CHP-funded officers 

are required to be the personnel specifically engaged in the community 

policing activities described on the application, consistent with best 

practices, would better position the COPS office to ascertain from 

applicants how these particular officers’ activities would advance 

community policing.

 

33The point estimate is 17 percent, and the associated 95 percent confidence interval is 

(10, 25). 
 

Page 22 GAO-13-521 Community Policing Hiring Grants

To help ensure that grantees are implementing the activities and meeting 

the financial requirements they committed to in their respective 

applications, the COPS Office is required to monitor at least 10 percent of 

its open, active grant funding annually.34 According to the Domestic 

Working Group’s guide for improving grant accountability, it is important 

that agencies identify, prioritize, and manage potential at-risk grantees. 

Consistent with this best practice and to fulfill its statutory monitoring 

requirement, the COPS Office uses a risk-based approach to select which 

grantees to monitor and visit using its Grant Assessment Tool (GAT), 

which is currently used by the COPS Office to assess grantee risk.35 The 

GAT uses criteria to generate individual risk scores, as illustrated in table 

3, and a final, comprehensive risk assessment score is computed for 

grantees.

 

34See 42 U.S.C. § 3712h. 

35According to COPS Office officials, all grantees are required to submit quarterly 

progress reports that provide financial and programmatic information, such as their 

progress in implementing the community policing plans they described in their grant 

applications. 

The COPS Office’s 

Monitoring Process 

Assesses How 

Grantees Are Using 

CHP Funds to 

Advance Community 

Policing, but Could Be 

Improved through 

Additional Monitoring 

Guidance 

The COPS Office Takes a 

Risk-Based Approach to 

Grant Monitoring and Has 

Processes to Monitor How 

Grantees Are Using Funds
 

Page 23 GAO-13-521 Community Policing Hiring Grants

Table 3: Community Oriented Policing (COPS) Office Grant Risk Assessment Tool Criteria Examples

Risk criteria Risk score

Grant award value More than $1,000,000: 4

More than $500,000: 2

Less than $500,000: 0

Late grant federal financial reports:

These reports are submitted quarterly and are used to report the amount of federal 

grant and local matching funds used to implement the grant. 

More than two late reports: 2

One late report: 1 

No late reports: 0

Waiver on matching funds requirement authorized Received a waiver: 4

Did not receive a waiver: 0

Local matching funds required Yes: 2

No: 0

Undergoing a DOJ (IG) audit or grantee has recent open audit recommendations:

The IG conducts performance and financial audits of select individual grantees, 

and these audits can include recommendations related to these grantees.

Yes: 4

No: 0

Grant modifications requested by grantees: Modifications can involve but are not 

limited to cost items or the classification of the hiring, such as changing awards 

from new hire to rehire. 

2 modifications requested: 1

3 modifications requested: 3

Grant extensions:

Grantees can request extensions on grant time periods in order to implement their 

grants. 

Extension provided for between 2 and 5 years: 2

Extension provided for more than 5 years: 4

Source: GAO analysis of the COPS Office’s risk assessment approach.

Once the monitors review what the GAT has generated, they are to 

develop a plan for monitoring those grantees with the highest risk scores. 

According to the COPS Office’s monitoring standards—a guide that 

describes the responsibilities of grant monitors—the COPS Office 

monitors these grantees in a number of ways, including, but not limited to, 

on-site monitoring, office-based grant reviews, and complaint and legal 

reviews.36 During on-site monitoring visits, monitors are required by the 

monitoring standards to review and compare the proposed projects and 

activities contained in grant applications and quarterly progress and 

financial status reports with those of the grantees’ performance and 

progress in carrying them out.37 Upon completion of their visits, monitors 

 

36DOJ, Grant Monitoring Standards and Guidelines for Hiring and Redeployment, 

Community Oriented Policing Services (COPS) Office, (Washington, D.C.: Sept.16, 2004).

37In some cases, OJP’s Office of the Chief Financial Officer will conduct joint site visits 

with COPS Office programmatic monitors in cases requiring more in-depth reviews of 

grantee financial management of grant funding. 
 

Page 24 GAO-13-521 Community Policing Hiring Grants

are required to document their observations and assessments in a grantmonitoring report and cite any grant compliance issues, which may be 

cited in categories including community policing, retention, allowable 

costs, and the source and amount of matching funds.

Office-based grant reviews, which are used to provide detailed monitoring 

for those grantees that are not selected for on-site monitoring using the 

GAT, are similar to on-site reviews in that monitors are required to review 

grantee documentation, including the application, and follow up directly 

with the grantee to collect any additional information and documentation 

on how grantees are using funds. This type of monitoring, according to 

COPS Office monitoring standards, allows the COPS Office to monitor a 

larger number of grantees than would be possible through on-site 

monitoring alone. In addition to these monitoring methods, the COPS 

Office also uses complaint reviews to investigate internal and external 

complaints, such as those raised by the media and citizens, regarding 

grantee noncompliance. The COPS Office’s Legal Division also conducts 

additional monitoring related to, among other things, supplanting—using 

federal funds to replace state or local funds—and DOJ IG investigations 

of grantees involving fraud. According to the monitoring standards, all of 

these monitoring efforts help the COPS Office determine whether the 

grantees are complying with the requirements of the grant and that funds 

are spent properly. Accordingly, the COPS Office uses these various 

monitoring methods to identify any grant violations, such as not using the 

funds to hire officers for deployment in community policing, and 

recommend resolutions to these violations. In cases where the grantee 

has failed to remedy violations identified by the monitor, the grantee, 

according to the monitoring standards, may be faced with adverse current 

and future determinations regarding its suitability for receiving grant 

funds, the suspension or termination of grant funds, repayment of 

expended grant funds to the COPS Office, and even criminal liability in 

the event of fraud.
 

Page 25 GAO-13-521 Community Policing Hiring Grants

The authorizing statute for the COPS grant programs, including CHP, 

requires that grantees not supplant state and local funding, but rather use 

the federal funds for activities beyond what would have been available 

without a grant.38 As a condition of accepting COPS Office funding, grant 

applicants must certify they will use grant funding only to increase the 

total amount of funds available for the hiring or rehiring of law 

enforcement officers and not supplant state and local funding. To identify 

supplanting risks, the COPS Office developed standards for monitors to 

use in assessing the potential for supplanting, which is one of the 

compliance issues monitors are required to evaluate. Monitors can use 

these supplanting standards in all forms of monitoring, including on-site, 

office-based desk, complaint, and Legal Division reviews. The standards 

contain clear guidance for identifying potential noncompliance with 

supplanting standards. For example, according to the COPS Office’s 

grant monitoring standards and, as illustrated in table 4, there are four 

major patterns of risk associated with supplanting.39

 

3842 U.S.C. § 3796dd-3. For the purpose of COPS Office grants, supplanting means using 

COPS Office grant funds to replace state or local funding—or, in the case of Indian tribal 

governments, funding supplied by the Bureau of Indian Affairs—that otherwise would have 

been spent on the specific law enforcement purpose of the COPS Office grant award.

39DOJ, Office of Community Oriented Policing Services, Grant Monitoring Standards and 

Guidelines for Hiring and Redeployment, (Washington, D.C.: Sept. 16, 2004).

The COPS Office Has 

Standards for Monitoring 

Supplanting, but Could 

Strengthen Its Guidance 

for Documenting 

Supplanting Analysis in 

Monitoring Reports
 

Page 26 GAO-13-521 Community Policing Hiring Grants

Table 4: Community Oriented Policing (COPS) Office Supplanting Identification Guidance for Monitors

Supplanting risk pattern Description 

Hiring sworn officers before the grant award date This may be an indication that the grantee is using COPS Hiring 

Program (CHP) funding to support officers already onboard which 

is inconsistent with the program requirements to increase the total 

number of officers. 

Delays in filling vacant locally funded sworn officer positions Any delay in filling locally funded vacancies must not be a direct 

result of receiving grant funds; otherwise, it may be considered 

supplanting.

Decreases in the baseline level of funding for locally funded 

sworn officers during the grant period

For any reductions in state and local funding levels for sworn 

officers that occurred in proximity to receiving the CHP award, the 

grantee must show that such reductions were unassociated with 

the award by providing evidence, such as city council minutes, 

memorandums, budgets, or other documentation, that shows the 

decreases were unassociated with receiving a CHP award.

Decreases in the baseline level of sworn officer positions during 

the grant period

If, during the grant period, the state and local baseline levels for the 

number of sworn officers has decreased, the grantee must be able 

to demonstrate by providing evidence, such as city council minutes, 

memorandums, budgets, or other documentation, that shows the 

decreases during the grant period were unassociated with CHP 

funding. Such documentation could show decreases related to 

fiscal distress, civilianization of sworn positions, or a management 

reorganization unrelated to the CHP award, to comply with the 

nonsupplanting requirement.a

Source: GAO analysis of COPS Office policy.

a

Some law enforcement agencies employ civilian police employees to conduct criminal justice work, 

such as crime identification and analysis. Civilianization of sworn positions refers to the use of civilian 

employees instead of sworn police officers to conduct criminal justice work.

The CHP supplanting standards also require grant monitors to conduct an 

analysis and review of supporting evidence to ensure grantees have not 

engaged in supplanting. Some of the acceptable documentation, 

according to the COPS Office, can be: 

• budget documents that can show the replacement rate of officers has 

remained consistent,

• documentation that shows the grantee has experienced fiscal 

distress, or

• city council minutes showing there has been difficulty in local hiring.

The standards do not specify how monitors should document their 

analysis and conclusions about potential supplanting issues in the 

monitoring reports they prepare after site visits. According to COPS Office 

officials, these reports are a critical component of the monitoring process. 

The COPS Monitoring Operations Manual—a technical guide for 

monitoring—requires monitors to identify and provide relevant details in 
 

Page 27 GAO-13-521 Community Policing Hiring Grants

monitoring reports where supplanting is identified. However, it does not 

require monitors to document their analysis and conclusions in instances 

in which the determination is ultimately made that supplanting has not 

occurred. As a result, it may be unclear how the monitors assessed these 

cases to reach conclusions that supplanting had not occurred in these 

instances. In our review of the monitoring reports for 39 of 55 grantees 

that had already begun to use CHP funds and were visited by grant 

monitors, we found 21grantees for which there was a pattern of risk for 

potential supplanting. For 16 of these 21, we concluded that the site visit 

reports clearly documented the analysis and conclusions reached by the 

monitors regarding supplanting issues. For example, one monitor noted in 

a site visit report that potential supplanting existed because a police 

department failed to fill local vacancies at the same time it hired officers 

using COPS grant funds. The monitor determined that there was no 

violation for supplanting based on information provided during and after 

the site visit demonstrating that the department was taking active and 

timely steps to fill local vacancies and that the department was prohibited 

from filling vacancies earlier because of a town-wide spending freeze. 

The site visit report listed the documentation that the monitor reviewed in 

making a determination that there was no violation, including copies of 

budget documents demonstrating town-wide cuts in personnel and the 

town’s fiscal distress, a memorandum implementing a town-wide 

spending freeze, an online job posting for the vacant officer positions, and 

the police department’s request to the town for authorization to fill the 

vacancies.

However, for the remaining 5 of 21 grantees, we found that the monitors 

did not document their assessments of supplanting issues, and it was not 

clear how they reached conclusions regarding potential supplanting. The 

reports for these 5 grantees indicated that there were delays in filling 

vacancies for locally funded officer positions at the time when officers 

were hired for CHP-funded positions. For example, in one report, the data 

showed that there were over 50 vacant locally funded positions in fiscal 

year 2010 that continued to be unfilled in fiscal year 2011, when the same 

department hired 27 officers with COPS funding. When the monitor 

visited the department in August 2012, there were still 59 locally funded 

vacancies. The site visit report noted that the department anticipated 

filling the vacancies in November 2012 and did not discuss any 

supplanting compliance issues. The report did not provide details on 

documentation reviewed or other information obtained to demonstrate the 

analysis performed or the basis for determinations on potential 

supplanting issues. It was unclear from this whether or how the monitor 

had assessed potential supplanting issues. In following up with the COPS 
 

Page 28 GAO-13-521 Community Policing Hiring Grants

Office on this case, officials provided us with additional evidence that the 

monitor had assessed supplanting and determined it had not occurred. 

Specifically, the monitor obtained documentation from the police 

department supporting that the department had completed recruitment for 

the positions and was in the middle of the applicant selection process. 

COPS Office officials also provided us with additional information that 

monitors had obtained on site visits for the other 4 cases that was not 

included in the monitoring reports, but supported that the monitors had 

assessed potential supplanting issues and determined supplanting had 

not occurred. Including this information in the site visit reports would 

document that supplanting issues were properly assessed in accordance 

with the monitoring standards.

Given the statutory prohibition against the supplanting of federal funds 

and the importance of documentation for agency accountability, monitors 

should consistently document the results of their supplanting analysis in 

the monitoring reports for on-site monitoring. According to Standards for 

Internal Control in the Federal Government, the documentation of agency 

activities is a key element of accountability for decisions.40 By enhancing 

the COPS Office’s monitoring guidance, such as its standards or 

operations manual, to require monitors to document the results of their 

supplanting analysis in the on-site monitoring reports for instances where 

the determination is made that no supplanting has occurred, the COPS 

Office could be better positioned to ensure that monitors are consistently 

assessing supplanting and that CHP funding is supplementing and not 

replacing state and local funding. Additionally, ensuring that monitors 

consistently document the results of their supplanting analysis would 

increase transparency and enhance oversight of CHP funds.

The COPS Office awarded approximately $1.7 billion in grant funds from 

fiscal year 2008 through 2012 for hiring officers to advance community 

policing. To ensure that grantees are using the funds as intended by the 

program, the COPS Office’s CHP application collects information required 

by statute, including information on how applicants will implement 

community policing on an agency-wide scale. However, the application 

does not require prospective grantees to provide information on the 

specific community policing activities of CHP-funded officers or a 

 

40GAO/AIMD-00-21.3.1/. 

Conclusions 
 

Page 29 GAO-13-521 Community Policing Hiring Grants

commensurate number of experienced locally funded officers. Revising 

the application to clarify for applicants that CHP-funded officers are 

required to be the personnel specifically engaged in the community 

policing activities described on the application, consistent with best 

practices, would better position the COPS office to ascertain from 

applicants how these particular officers’ activities would advance 

community policing. In addition, we found that while the COPS Office has 

developed standards and an operations manual for monitors to use in 

assessing the potential for supplanting, the COPS Office’s monitoring 

standards and operations manual do not require monitors to document 

their analysis and conclusions in instances in which the determination is 

ultimately made that supplanting has not occurred. We found that for 5 of 

the 21 grantees for whom we identified as at risk for supplanting, the 

monitors included information in the monitoring reports on supplanting, 

but did not document their assessments of the supplanting issues. 

Enhancing the COPS Office’s monitoring guidance, such as its standards 

or operations manual, to require monitors to document the results of their 

supplanting analysis in the on-site monitoring reports for instances where 

the determination is made that no supplanting has occurred could better 

position the COPS Office to ensure that monitors are consistently 

assessing supplanting and ensuring that CHP funding is supplementing 

and not replacing state and local funding.

To further enhance the accountability of the CHP, the Attorney General 

should direct the COPS Office Director to take the following two actions: 

1. revise the CHP application to clarify for applicants that CHP-funded 

officers are required to be the personnel specifically engaged in the 

community policing activities described on the application; and

2. enhance the COPS Office’s guidance, such as its monitoring 

standards or operations manual, by requiring monitors to document 

the results of their supplanting analysis in on-site monitoring reports 

for instances where the determination is made that no supplanting has 

occurred.

. 

We provided a draft of this report to DOJ and the COPS Office for review 

and comment. The COPS Office provided written comments on the draft 

report, which are summarized below and reproduced in full in appendix 

III. The COPS Office concurred with the two recommendations in the 

report and identified actions planned to implement the recommendations. 

The COPS Office also discussed concerns it had with the discussion of 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 30 GAO-13-521 Community Policing Hiring Grants

the grant application and wording of the second recommendation in the 

draft report. 

The COPS Office concurred with the first recommendation, that the 

COPS Office revise the CHP application to clarify for applicants that CHPfunded officers are required to be the personnel specifically engaged in 

the community policing activities described on the application. The COPS 

Office stated that, in response to the recommendation, it clarified in the 

current CHP Grant Owner’s Manual and will clarify in subsequent years’ 

CHP applications that the questions in the grant application apply not only 

to the agency overall but to the CHP-funded officers as well. Once the 

COPS Office has taken action to fully implement this recommendation, it 

will be better positioned to ascertain from applicants that officers’ 

activities would advance community policing. 

While the COPS Office concurred with the recommendation, it raised 

concerns in its letter about how we characterized the way the COPS 

Office collects information via the CHP application on the activities of 

CHP-funded officers. Specifically, the COPS Office disagreed with the 

statements that (1) the 2012 CHP application does not specifically ask 

applicants to explain how CHP-funded officers will be deployed in

community policing and that (2) less than 20 percent of the applications 

funded in 2010, 2011, and 2012 contained evidence showing how 

additional CHP-funded officers would be deployed to community policing. 

According to the COPS Office, the CHP application contains over 70 

individual close-ended questions and 3 narrative questions regarding 

activities that CHP-funded officers and agencies will commit to as a 

requirement of the grant. The report acknowledges that the COPS Office 

collects an array of information from applicants on the agency-wide 

activities they plan to conduct. However, our analysis—including the 

analysis of a systematic random sample of CHP-funded applications—

was intended to demonstrate the extent to which CHP applications 

contained information about how additional officers would be deployed in

community policing in the absence of the application not specifically 

asking applicants to describe which community policing activities 

individual CHP-funded officers will undertake. Revising the application to 

clarify for applicants that CHP-funded officers are required to be the 

personnel specifically engaged in the community policing activities 

described on the application, consistent with best practices, would better 

position the COPS Office to ascertain from applicants how these 

particular officers’ activities would advance community policing. 
 

Page 31 GAO-13-521 Community Policing Hiring Grants

The COPS Office also disagreed with a statement in the draft report that 

the COPS Office stated that there could be benefits to revising the 

application to more clearly delineate the activities in which CHP-funded 

officers should be engaged. Rather, the COPS Office stated in its letter 

that the application could be clearer by stating that the office is requiring 

that COPS-funded officers should be the ones who are specifically 

engaged in CHP- funded activities. We modified the recommendation and 

related language in the report to reflect this point. We provided the 

modified recommendation language to the COPS office, and on 

September 19th in an e-mail from CHP program officials, the office 

concurred. 

The COPS Office concurred with the second recommendation to enhance 

the COPS Office’s monitoring guidance by requiring monitors to

document the results of their supplanting analysis in on-site monitoring 

reports for instances where the determination is made that no supplanting 

has occurred. The office stated that it had checks and balances in its 

monitoring practices on the review of grantee documents and guidance 

for documenting analysis results when supplanting is identified. 

While the COPS Office concurred with the recommendation, it noted in its 

letter that our recommendation as originally worded implied that the 

existing monitoring guidance does not require grant monitors to document 

the results of their supplanting analysis for cases in which supplanting 

has been identified. Since the COPS Monitoring Operations Manual 

requires monitors to identify and provide relevant details in the monitoring 

reports regarding instances in which supplanting has occurred, the COPS 

Office requested that we amend the recommendation with language 

stating that the monitoring reports be enhanced by ensuring that monitors 

document the results of their supplanting analysis in instances that do not 

give rise to supplanting concerns. We adjusted the recommendation and 

related language accordingly to clarify this point. 

Further, in response to the recommendation, the COPS Office outlined 

initiatives it has implemented to modify its COPS Monitoring Operations 

Manual that reflect changes to data collection tools and instructions on 

how monitors should document their supplanting analysis, including 

instances in which monitors determine that no supplanting has occurred, 

in the monitoring reports. These actions, if implemented effectively, 

should address the intent of the recommendation. 

We are sending copies of this report to the Assistant Attorney General 

For Administration, and interested congressional committees. In addition, 
 

Page 32 GAO-13-521 Community Policing Hiring Grants

this report is available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-9627 or maurerd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix III.

David C. Maurer

Director

Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-521 Community Policing Hiring Grants

This report answers the following questions: (1) From fiscal years 2008 

through 2012, in what areas of the country was the Community Oriented 

Policing Services (COPS) Hiring Program (CHP) funding disbursed and to 

what extent did award amounts vary during this period? (2) To what 

extent does the COPS Office’s grant application collect information about 

how applicants plan to use CHP-funded officers to advance community 

policing? (3) To what extent does the COPS Office’s monitoring process 

assess whether grantees are using funds to advance community 

policing?

To address the first question, we reviewed the history of the COPS 

Office’s programs and related award data from the most recent 5 fiscal 

years—2008 through 2012—and confirmed that CHP received the largest 

share of award funds as compared with other programs administered by 

the COPS Office during this period. We also analyzed COPS Office 

documentation, such as Grant Owner’s Manuals and COPS Office 

website materials, to learn about each COPS program’s origin and 

emphasis. To determine which areas of the United States have received 

CHP funding, we analyzed the allocation of CHP grant awards—and the 

numbers of officers funded—by state and mapped the CHP grant award 

data. Additionally, we analyzed CHP award lists for fiscal years 2008 

through 2012 to determine the average CHP entry-level officer salary and 

benefits by state, and assessed them for variation.1 To assess the 

reliability of data used in our review, we reviewed system tests that the 

COPS Office conducts periodically to ensure data reliability and 

interviewed COPS Office officials about the integrity of the data they 

provided to us. We determined that the data were sufficiently reliable for 

the purposes of our report. We also interviewed COPS Office officials 

responsible for managing the CHP program to verify grant program 

information, determine factors that could account for variations in grant 

award amounts, and learn about other administrative aspects of the 

program.

To address the second question, we assessed CHP documentation, 

including CHP grant applications and Grant Owner’s Manuals to 

determine how the COPS Office’s application collects information about 

 

1

We focused our review of grant award lists from fiscal years 2009 through 2011 because 

during this period the COPS Office awarded each grantee the full amount it cost the 

grantee to pay the salaries and benefits of each funded officer. In both fiscal years 2008 

and 2012, appropriations language removed the caps, as we discuss later in the report.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-521 Community Policing Hiring Grants

how applicants plan to use CHP-funded officers to advance community 

policing. We examined the CHP authorizing statute and best practices for 

grants management identified in the Domestic Working Group Grant 

Accountability Project’s Guide to Opportunities for Improving Grant 

Accountability and compared the criteria outlining promising practices for 

grant applications, such as designing applications to gather sufficient 

information for making award decisions, with the COPS Office’s 

approaches for designing the CHP application.2

To better understand these approaches, we reviewed the CHP 

application design, allowable activities, and the COPS Office’s criteria for 

selecting awardees. Specifically, we used elements of the CHP 

authorizing statute and key best practices for grant management to 

develop a data collection instrument we used to review all applications 

from a sample of 103 out of the 841 grants awarded during fiscal years 

2010, 2011, and 2012. We chose to evaluate applications from these 3 

fiscal years to provide an assessment of the most recent fiscal years’ 

application design. Using the data collection instrument, we reviewed the 

application sample to determine, among other items, the applications’ 

level of detail in describing applicants’ planned use of funds. Each 

application was first reviewed by an analyst, and the information recorded 

in each completed instrument was then verified by a second analyst. To 

ensure a selection of grants representative of the dollar amount 

distribution in the population of 841 awarded grants, we sorted the 

population by the grant dollar amount and then selected a systematic 

random sample of 104 grants.3 During our review, we discovered that 1 

grant in our sample was out of scope because the grantee did not accept 

the grant funds and was no longer considered an active grantee. We 

reviewed the remaining 103 grant applications in our sample and treated 

them as a simple random sample for purposes of estimation. Because we 

followed a probability procedure based on random selections, our sample 

is only one of a large number of samples that we might have drawn. 

Since each sample could have provided different estimates, we express 

our confidence in the precision of our particular sample’s results as a 95 

 

2

Domestic Working Group, Grant Accountability Project, Guide to Opportunities for 

Improving Grant Accountability (Washington, D.C.: October 2005).

3

A systematic random sample is a method of sample selection in which the population is 

listed in some order, in this instance dollar amount of grant awarded, and every kth 

element is selected randomly for the sample.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-521 Community Policing Hiring Grants

percent confidence interval (e.g., plus or minus 9 percentage points). This 

is the interval that would contain the actual population value for 95 

percent of the samples we could have drawn. With the finite population 

correction factor, the precision for estimates drawn from this sample is no 

greater than plus or minus 9 percentage points at the 95 percent level of 

confidence. To ensure the reliability of data used in our review, we 

interviewed COPS Office officials about the integrity of the data they 

provided to us and reviewed system tests that the COPS Office conducts 

periodically to ensure data reliability. We also ensured that the electronic 

data CHP applicants submitted could not be altered once submitted to the 

COPS Office. We determined that the data were sufficiently reliable for 

the purposes of our report.

We also conducted interviews with a nonprobability sample of 20 CHP 

grantees in California, Florida, Illinois, Massachusetts, Texas, and 

Wisconsin. We selected these grantees from five metropolitan areas 

according to criteria that included the amount of funding received by the 

grantees, the concentration of grantees within a metropolitan area to 

maximize the amount of information we could collect, and the population 

size served by grantees. The results of these interviews are not 

generalizable to all grantees, but provided insight, among other things, 

into how CHP grant funds are used locally to advance community 

policing. Finally, we interviewed COPS Office officials who oversee the 

application process to gather further information on the design of the 

application, including how the applications were scored.

To address the third question, we obtained and examined the monitoring 

reports for 55 grantees awarded CHP grants from the 3 most recent fiscal 

years—2010 through 2012—with completed, available monitoring 

reports.4 The COPS Office produced these reports following the on-site 

monitoring visits it conducts with grantees to assess their progress and 

identify any compliance issues for CHP grants. Specifically, we developed 

a data collection instrument to review the monitoring reports to assess the 

extent to which the COPS Office identified and documented supplanting. 

We used the questions on the data collection instrument to make these 

assessments. Each report was first reviewed by an analyst, and the 

 

4

As with the grant applications we selected for review, we selected these 3 years because 

they reflected the most recent active CHP awards, each of which remains open for a 3-

year grant term. These 55 grantees were all of the grantees from this period for which the 

COPS Office had completed CHP grant-monitoring reports at the time we began our audit. 
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-13-521 Community Policing Hiring Grants

information recorded in each completed instrument was then verified by a 

second analyst. We then compared the COPS Office’s monitoring 

practices with best practices identified in the Domestic Working Group 

Grant Accountability Project’s Guide to Opportunities for Improving Grant 

Accountability; Standards for Internal Control in the Federal Government; 

and COPS Office guidance, such as its grant-monitoring standards.5 For 

context, we also considered findings from prior GAO work on program 

evaluation and the COPS Office’s management of its grant programs.6 To 

understand how the COPS Office assesses the potential for supplanting, 

we used COPS Office guidance on determining supplanting in reviewing 

the monitoring reports to identify grantees at risk of using CHP funds to 

replace state and local funds. Additionally, we assessed how the monitors 

addressed and documented instances in which grantees were vulnerable 

to supplanting, such as collecting and evaluating additional budget 

documentation from grantees. During the site visits, we interviewed CHP 

grantees about, among other topics, the community policing strategies 

they employed with CHP funding and whether their agencies had 

increased the number of officers dedicated to community policing relative 

to the number of officers hired with CHP funding. We also interviewed 

COPS Office officials who oversee the monitoring process about their 

monitoring practices and discussed with officials how monitoring provided 

relevant context to what grantees and the COPS Office considered 

progress. We also obtained the perspective of the COPS Office on the 

performance of its grant monitors in identifying and documenting 

instances of potential supplanting in the reports for on-site monitoring

We conducted this performance audit from August 2012 to September 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

 

5

Domestic Working Group, Grant Accountability Project, Guide to Opportunities for 

Improving Grant Accountability. 

6

GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington D.C.: Jan. 31, 

2012). DOJ Office of the Inspector General, Improving the Office of Community Oriented 

Policing Services’ Grant Awarding, Monitoring, and Program Evaluation Processes, 

(Washington, D.C.: June, 2009). DOJ, Grant Monitoring Standards and Guidelines for 

Hiring and Redeployment, Community Oriented Policing Services (COPS) Office, 

(Washington, D.C.: Sept.16, 2004).
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-521 Community Policing Hiring Grants

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: How Proactive and Reactive 

Policing Differ

Page 38 GAO-13-521 Community Policing Hiring Grants

This appendix corresponds with figure 1 in the report, which is an 

interactive figure. Table 5 contains the text that is not accessible to 

readers of print copies of this report.

Table 5: How Proactive and Reactive Policing Differ

Aspects of proactive and reactive 

policing Description in pop-up box

Reactive policing

911 Citizens report crime by dialing 911 and in some jurisdictions, can text police departments to 

report crime. 

Police response Generally, police assigned to the police patrol answer 911 service calls based upon their 

geographical area of assignment. 

Reactive policing Intervention Sworn police officers responding to 911 service calls generally have a variety of options to 

address a specific crime, such as issue warnings and citations or arrest suspects of crime for 

referral to the court system. 

Proactive policing

Crime problem identification Identified through strategies such as Community Policing—through proactive interaction with 

the community, officers receive information about specific types of crime problems. Through 

this proactive interaction, officers gain legitimacy with the community, which creates a selfperpetuating cycle of community feedback.

Examples of Proactive Community Policing Activities:

Neighborhood Police Liaisons

Police communicate with citizens in an assigned neighborhood and engage in order 

maintenance, such as ordinance violations and housing code enforcement, which can lead to 

crime.

School Resource Officers

Deployed inside schools to proactively address such problems as drug use and distribution, 

and to generally prevent delinquency. 

Intelligence gathering Gathered through a variety of police strategies such as

police investigations in response to reported crime,

911 service call reporting,

cooperative victims assisting police, and

specialized units gathering intelligence such as anti-gang or neighborhood response.

Crime analysis Software programs such as CompStat allow law enforcement to collect and analyze data in 

order to map areas of high crime.

Some police departments employ crime analysts who are typically non-sworn employees to 

conduct analysis to identify causes of crime problems so that departments can dedicate an 

appropriate level of resources to intervention strategies. 

Appendix II: How Proactive and Reactive 

Policing Differ
Appendix II: How Proactive and Reactive 

Policing Differ

Page 39 GAO-13-521 Community Policing Hiring Grants

Aspects of proactive and reactive 

policing Description in pop-up box

Proactive policing intervention Through the identification and analysis of crime information, law enforcement personnel use 

a variety of strategies to prevent and solve crime problems, including:

Order maintenance

Whereby disorder in the community such as graffiti and abandoned cars can be addressed 

and therefore reduces the chances that particular areas will experience more serious crime in 

the future.

Hot spot policing

Through the use of crime mapping, law enforcement can prevent crime through the 

redeployment of officers to areas experiencing high levels of crime. Officers can be deployed

in a variety of ways, including bike, automobile, and foot patrol, where they may be able to 

respond to 911 service calls quickly or may generally be seen as a crime deterrence.

Multiagency task forces

Some law enforcement agencies leverage resources across law enforcement agencies using 

analyzed data such as data about human or illegal drug trafficking to interdict these crimes.

Resolution Not all interventions require crime problems and the perpetrators of crime to be addressed by 

the court system. Interventions such as order maintenance are known to deter future crime 

and generally do not require arrest and referral of cases to the court system.

Other results that are more likely to require the referral of cases to the court system are when 

the interventions are directly focused on perpetrators of crime and not necessarily on the 

environmental conditions related to crime. Such referrals and successful adjudications both 

remove criminals from society and provide for a general deterrence of crime. 

Source: GAO.
Appendix III: Comments from the Department 

of Justice

Page 40 GAO-13-521 Community Policing Hiring Grants

Appendix III: Comments from the 

Department of Justice
Appendix III: Comments from the Department 

of Justice

Page 41 GAO-13-521 Community Policing Hiring Grants
Appendix III: Comments from the Department 

of Justice

Page 42 GAO-13-521 Community Policing Hiring Grants
Appendix III: Comments from the Department 

of Justice

Page 43 GAO-13-521 Community Policing Hiring Grants
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 44 GAO-13-521 Community Policing Hiring Grants

David C. Maurer, (202) 512-9627 or maurerd@gao.gov

In addition to the contact named above, key contributors to this report 

were Joy Booth, Assistant Director; Glenn Davis, Assistant Director; 

David Alexander; Carl Barden; Christine Hanson; Eric Hauswirth; Julian 

King; Linda Miller; Christian Montz; Robin Nye; Brian Schwartz; and Janet 

Temko.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441100)
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